Environmental Management Plan

Minimizing the Impact on the Environment

Introduction

Flexera Software LLC ("Flexera Software") is committed to minimizing the impact of its activities on the environment, and is implementing a plan to achieve this end. The key points of the company's strategy include:

Minimize waste by evaluating operations and ensuring they are as efficient as possible

Actively promote recycling

Meet or exceed all the environmental legislation that relates to the Company

Flexera Software is currently in the planning stages of implementing a sustainability plan through development of an Environmental Management Plan (EMP). Our EMP will follow the Environmental Protection Agency's suggested guidelines, which are as follows:

Plan: Identifying environmental aspects and establishing goals

Do: Implementing that plan, including training and operational controls

Check: Monitoring the plan's success and taking corrective action

Act: Track progress and make necessary changes

Compliance Plan

Flexera Software's EMP plan includes the following components:

EMP deployment by establishment of a baseline for energy usage in a 12-month period in order to address seasonal trending when possible. The baseline period will be defined as September 2010 to September 2011. If a baseline is not possible to establish, we will make attempts to measure what we can and strive to make improvements when possible.

Energy Consumption

Electric – The baseline is 945,205 Kilowatts consumed

Scope 2 Greenhouse Gas Emissions

Electric – The baseline is 652 metric tons scope 2 impact

Waste Management and Recycling

Recycling Volume –Tons of recycling material picked up by recycling company for Flexera Software's facilities: The baseline is 33,600 pounds of recycled material.

Waste Volume - Tons of trash picked up by garbage company for Flexera Software's facilities: This metric is not currently available. We will make reasonable efforts to obtain this information and set appropriate goals

Working off of these baselines, Flexera Software has set one goal for each category. Progress will be tracked on an annual basis.

Goals will be set by Flexera Software senior management, and follow the format below. A major challenge in setting these goals is the location of our facilities in multi-tenant buildings; therefore, measurements are based on the acts of all tenants as a whole, which can significantly affect our ability to accurately project and meet our EMP objectives. We have taken this into account and will work to meet our goals.

Waste volume data is not currently available to Flexera Software. We will make reasonable efforts to obtain this information and set appropriate goals

We will share our conservation plans with all employees. Each employee will have access to the EMP and acknowledge that he or she will support it through actions such as making sure paper is recycled, trash is minimized, etc.

We will form a committee that meets quarterly. This committee will review the progress of reduction initiatives against the EMP goals; discuss any need for redirection, etc.

We expect all of our suppliers to act in an environmentally friendly manner in accordance with guidelines similar to those contained in this Environmental Management Plan.

Flexera Software has not been assessed any fines or penalties of a material nature with regard to environmental activities.